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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and exhibits attached thereto are
incorporated herein. At the time the petition was filed in this
case, petitioner resided in Metairie, Louisiana.
Petitioner and his spouse2 filed a joint Federal income tax
return for taxable year 1980 on April 16, 1981. The couple
timely filed joint Federal income tax returns for taxable years
1981, 1982, and 1983.
In 1957, petitioner began working for Avondale Shipyards,
Inc. (ASI). During the early 1970's, petitioner was the
assistant superintendent of ASI’s paint department (occasionally
the paint department). Petitioner became the superintendent of
the paint department in 1975 and remained in that position
throughout the years at issue.
Besco Exporting Corporation (Besco) was a manufacturer of
industrial chemicals. During the years at issue, Besco was owned
by James Tubre (Tubre) and Seligman Kahn (Kahn). In promoting
its products, Besco routinely sought to gain "in the yard" status
with its customers. "In the yard" status meant physical and
ongoing access to customer job sites. This practice enabled
Besco to make first-hand field observations of the particular
2Petitioner’s spouse is not a party to this proceeding.
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